Compliance Statement

Castolin Eutectic is committed to an environment where open, honest communications are the expectation, not the exception. We want you to feel comfortable in approaching us in instances where you believe violations of policies or standards have occurred.

In situations where you prefer to place an anonymous report in confidence, you are encouraged to use this hotline, hosted by a third-party hotline provider, EthicsPoint. The information you provide will be sent to us by EthicsPoint on a totally confidential and anonymous basis if you should choose.

The purpose of this Code is to provide guidance for business behavior in critical areas relating to the business activities of Castolin Eutectic. The Code does not cover every situation where compliance or ethical behavior may be required, but rather sets forth minimum standards and a spirit which are fundamental to the way we conduct our business.

Some of Castolin Eutectic’s basic values and principles include the following:

• We respect and comply with all applicable laws and regulations as well as with internal regulations, directives and guidelines. This means:
  • We do not give or take bribes. We avoid giving or receiving gifts which could create a conflict, violate the standards of those we are dealing with or violate the law.
  • We do not participate in any acts or omissions which could be considered violations of applicable competition and anti-trust laws, such as the written or verbal exchange of sensitive data with competitors.
  • We avoid conflicts of interest and disclose potential conflicts as early as possible.
  • We protect our confidential and proprietary information from unauthorized use.
  • We respect and secure our know-how and intellectual property rights.
• We conform to the locally accepted standards of good corporate citizenship in each country in which we do business.
• We promote and sustain a work environment that fosters mutual respect, openness and individual integrity, and we support and respect the protection of internationally proclaimed human rights.
• We report all incidents which in our good faith judgment raise concerns of misconduct or violations of laws, regulations or Company policy. 

Castolin Eutectic is committed to providing fair and non-discriminating employment practices which include providing equal employment opportunities in compliance with applicable laws. Castolin Eutectic respects different cultural backgrounds and is committed to complying with all employment and labor laws including those related to the elimination of all forms of forced and compulsory labor (including child labor) and the prohibition against all forms of discrimination in employment under applicable laws. We encourage our employees to balance work, family, and personal development commitments.

Castolin Eutectic is firmly committed to diversity and provides equal employment opportunities to all employees without regard to gender, race, color, age, religion, national origin or other discriminatory factors.

We keep accurate and complete business records. All our business transactions must be fully and fairly recorded in accordance with Castolin Eutectic’s accounting and financial reporting principles, and records are retained or destroyed in accordance with the record retention program of the Castolin Eutectic Company. False or misleading entries must not be made in the books and records of Castolin Eutectic or any of its subsidiaries for any reason.

Castolin Eutectic strictly forbids paying bribes, irrespective of whether the recipient is a public official or an employee of a private customer. Bribery is broadly defined and understood as a direct or indirect offer or acceptance of any gift, loan, fee, reward or other advantage to or from any person in order to obtain or reward favorable treatment in the conduct of one’s business.

Within its organization, Castolin Eutectic strictly applies the laws prohibiting the use of third parties (such as but not limited to agents, consultants or other service providers) to circumvent legal requirements as stipulated in applicable anti-corruption and anti-bribery laws. Castolin Eutectic refrains from cooperating with business partners who violate fundamental human rights, such as using forced and compulsory labor or child labor.

The ability of Castolin Eutectic to trade in the world market is restricted by regulations issued by various countries and international organizations such as the United Nations. The mere disclosure of technology may be considered an export. It is the policy of Castolin Eutectic to comply fully with the prohibitions and requirements of all applicable international trade laws and regulations, and all employees involved in these areas should be familiar with the local and international laws and regulations affecting their business. When in doubt, employees should seek advice from supervisors or appropriate legal support.

Castolin Eutectic is committed to design its products in accordance with applicable industry standards and relevant safety, health and environmental requirements. We support a precautionary approach to environmental challenges, undertake initiatives to promote greater environmental responsibility and encourage the development and diffusion of environmentally-friendly technologies. Castolin Eutectic strives to decrease the accident frequency as well as the accident severity rates in each company.

Fair competition is a fundamental principle of the free enterprise system and is fully supported by Castolin Eutectic. Therefore, Castolin Eutectic requires full compliance with applicable anti-trust and unfair competition laws, which among others include laws prohibiting unfair trade practices and restraints of trade. Anti-trust Laws address the business practices with suppliers, customers and competitors.

Although Anti-trust Laws vary from country to country, they typically address at least the following prohibited actions:

a)    Price Fixing Agreement with one or several competitors to fix or otherwise affect prices, terms or conditions of sales.
b)    Market/Customer Allocation Agreement with one or several competitors to divide up markets and/or customers.
c)    Bid-rigging Agreements with one or several competitors to refrain from bidding, to bid at a certain price or to submit a bid that is known to be less favorable than a competitor’s bid.
d)    Sharing of sensitive information. Obtaining or providing sensitive information (e.g. relating to current or future prices, profit margins or costs, bids, market shares, distribution practices, terms of sales, production plans) from or with competitors at meetings of trade, professional associations or elsewhere.

All Castolin Eutectic employees have a duty to ensure that their outside interests do not interfere with their obligations to the company. Therefore, they should avoid situations in which their personal interests, outside activities, relationships or financial interests appear to conflict with the interests of Castolin Eutectic.